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Paul90125

MTPLM Update

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2 minutes ago, Grandpa Steve said:

 

So if the caravan has a plate in the gas locker that specifies a maximum MTPLM which is the legal specification and is enforceable, then if that plated weight and your car exceeds the GTW of 3500kg then anyone on a lower Cat B licence category should not be able to tow that outfit, the door plate is a red herring.

 

Well you would  think so wouldn’t you? And you would be wrong!!

 

I started what turned into a a VERY lengthy thread on this very subject a month or so ago. I have tried to paste a link but it doesn’t seem to work, anyway it’s called “Caravan gross weight, a response from Bailey” in Caravan Chat.

 

Basically a manufacturer can produce a vehicle and have it type approved at a certain weight. Let’s say 1500kg. That’s the absolute maximum the vehicle can weigh on a road.

 

HOWEVER they can, if they wish, then set a LOWER MTPLM of their choosing on the same vehicle. Say 1425kg. If it’s the lower MTPLM showing on the outside decal, that’s the one that is used for enforcement purposes.

 

It’s a fairly common practice on HGV’s that are type approved (and can be plated) at 7750kg. That makes than an HGV so any driver requires an HGV licence. However that self same vehicle can be downplated to 7490kg which is often done to carry bulky, but lightweight cargo, thus negating the need for the driver to hold an HGV licence (because it’s below the magic 7500 MAM) It’s the same with caravans! Yes it’s daft and no I don’t know why it’s done, but it is! 

 

If you want a more more detailed explanation Wade thru the other thread!

 

Andy

 

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1 minute ago, Mr Plodd said:

If you want a more more detailed explanation Wade thru the other thread!

 

Andy

 

 

I followed it with interest, and despite what Bailey have said, in plain facts it should be the legally enforceable plated weights that are used, not a mickey mouse plate the dealer has stuck on the door to add smoke and mirrors, and confusion to what is a straight forward scenario.

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5 minutes ago, Mr Plodd said:

 

It’s a fairly common practice on HGV’s that are type approved (and can be plated) at 7750kg. That makes than an HGV so any driver requires an HGV licence. However that self same vehicle can be downplated to 7490kg which is often done to carry bulky, but lightweight cargo, thus negating the need for the driver to hold an HGV licence (because it’s below the magic 7500 MAM) It’s the same with caravans! Yes it’s daft and no I don’t know why it’s done, but it is! 

 

 

I think you are comparing apples with pears there, Mr. Plodd. The practice to downplate HGV's to under 7500kg involves fitting a new statutory plate. In the case of caravans we are not talking about changing the statutory plate but only bringing some sticker on the outside of the caravan in line with what is already shown on the statutory plate. That's a different issue altogether.

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Posted (edited)
1 hour ago, Lutz said:

 

I think you are comparing apples with pears there, Mr. Plodd. The practice to downplate HGV's to under 7500kg involves fitting a new statutory plate. In the case of caravans we are not talking about changing the statutory plate but only bringing some sticker on the outside of the caravan in line with what is already shown on the statutory plate. That's a different issue altogether.

 

Sorry but you are actually incorrect.

 

In my scenario the vehicle itself has a statutory plate showing say 7750 kg BUT the “Ministry Plate” shows a MGVW of 7490. The statutory plate STILL REMAINS at 7750. 

 

 It’s the 7490 ministry plate that will be used for ALL enforcement purposes, I.e. both vehicle weight AND driving licence rules. Like I said it’s a very common practice with that size of vehicle. It does defy kcommon sense to a degree as the vehicle itself doesn’t alter in the slightest, but one is classed and an HGV (with all the subsequent rules) and the other is basically a rather weighty car!! Same with a caravan (like mine) Statutory plate shows 1450kg yet it leaves the factory with a manufacturers designated MTPLM of 1397kg, and it’s THAT weight that is used for enforcement. At any time in the vehicles life the “Ministry Plate” CAN be up-plated  back UP TO (but not exceeding) the STATUTORY Plate max of 7750

 

 For a fee Bailey will issue a new certificate of conformity and a new external weight decal. 

 

Trust me I have spent a LOT of time and effort researching this very subject so speak from a point of knowledge.

 

Andy

1 hour ago, Grandpa Steve said:

 

I followed it with interest, and despite what Bailey have said, in plain facts it should be the legally enforceable plated weights that are used, not a mickey mouse plate the dealer has stuck on the door to add smoke and mirrors, and confusion to what is a straight forward scenario.

 

If you read the thread you will see that I had a lengthy, and pretty technical, chat with an expert from DVSA, and I am happy with the explanation given. You are of course perfectly entitled to disagree with him. 

 

I have done my very best to get a definitive answer to that very question. You are welcome to do the same if you think it’s wrong!

Edited by Mr Plodd

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2 minutes ago, Mr Plodd said:

 

Sorry but you are actually incorrect.

 

In my scenario the vehicle itself has a statutory plate showing say 7750 kg BUT the “Ministry Plate” shows a MGVW of 7490. The statutory plate STILL REMAINS at 7750. 

 

 It’s the 7490 ministry plate that will be used for ALL enforcement purposes, I.e. both vehicle weight AND driving licence rules. Like I said it’s a very common practice with that size of vehicle. It does defy common sense to a degree as the vehicle itself doesn’t alter in the slightest, but one is classed and an HGV (with all the subsequent rules) and the other is basically a rather weighty car!! Same with a caravan (like mine) Statutory plate shows 1450kg yet it leaves the factory with a manufacturers designated MTPLM of 1397kg, and it’s THAT weight that is used for enforcement.

 

 For a fee Bailey will issue a new certificate of conformity and a new external weight decal. 

 

Trust me I have spent a LOT of time and effort researching this very subject so speak from a point of knowledge.

 

Andy

 

OK, but the 'ministry plate' is covered in UK legislation, just as much as the statutory plate. However, it is a purely UK thing that would not enable an HGV with a statutory plate showing a weight over 7500kg to be driven by a holder of a C1 licence on the Continent, even if the ministry plate shows a value below that.

The label by the door, on the other hand, is not covered in any legislation so there is nothing to say that it must be put there by the manufacturer. If one wanted to retain one's Category B entitlement what is there to prevent one from making up one's own additional sticker with a note "I know the weight plate on this caravan shows an MTPLM of 1600kg but I promise never to load it over 1575kg", signed J Bloggs? That would  surely be just as legitimate as an NCC sticker.

You say Bailey will, for a fee, issue a new certificate of conformity. Let's qualify that. Bailey will issue a certificate of conformity according to NCC requirements. They will not issue a new type approval certificate of conformity and that is the only one recognised in legislation.

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Posted (edited)

Well I suggest YOU take up the matter with the DFT DVSA or whoever else you wish to. 

 

I got an answer from a senior man at the DVSA that I,  as someone who was closely involved in road traffic law for thirty years, I was happy with.

 

Clearly thats not good enough for you, that’s your choice but, to quote Dragons Den, I’m out!

 

I am more than happy to be proven wrong, so I challenge you to do eaxactly that.  But that will need proof not opinion.

 

Andy

Edited by Mr Plodd

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As you say, because of differing opinions it would need to be challenged in court in order to find a definitive answer, but the confusion is totally unnecessary and could be resolved by the manufacturers with little or no effort. As things stand, it is totally illogical to have two different values of MTPLM on the same caravan although the definition clearly can only refer to one.

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Posted (edited)

I would just like to add that nowhere in any legislation is there any reference to an 'assigned' MTPLM, a term that has only been used here in this forum.

Edited by Lutz

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35 minutes ago, Lutz said:

I would just like to add that nowhere in any legislation is there any reference to an 'assigned' MTPLM, a term that has only been used here in this forum.

 

Perhaps they should have the enforceable  figure as displayed on the plate in the gas locker as the MTPLM, and then have another acronym for the door plate such as MMDLM - Maximum Manufacturers Down Plated Laden Mass :)

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Posted (edited)

Perhaps MPBLM (Minimum Payload Based Laden Mass) would be more appropriate because it is based on a minimum payload, calculated according to industry standard BS EN 1645-2. It certainly can't be called a maximum whichever way you look at it.

 

Edited by Lutz
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Hey guys don’t give me a hard time, I didn’t make the rules!!! 

 

I tried VERY hard to get an unequivocal answer to this very matter as detailed in my previous thread. It got to the point where I was pretty happy with the answer I got from the man at DVSA, who very clearly knew the subject inside out and backwards. 

 

 It is POSSIBLE that if it ever got as far as court then the courts MIGHT put a  different interpretatation on it. I for one have neither the time, or more importantly, the money to persue it through the courts. 

 

The system as it currently is has been in place for many years yet no-one has ever challenged it at court. There is probably a good reason for that.

 

Continue to put  your interpretations on this matter by all means, but remember it’s not YOUR interpretation that counts.  It is, without a doubt, in desperate need of being clarified by a court.

 

Andy

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2 hours ago, Lutz said:

I would just like to add that nowhere in any legislation is there any reference to an 'assigned' MTPLM, a term that has only been used here in this forum.

 

A manufacturer can assign whatever MTPLM they wish PROVIDING it doesn’t exceed the Type Approved MTPLM for that vehicle. Yes it’s seems bizarre but that’s how it is. 

 

Andy

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Whew! Thanks guys!

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Posted (edited)
14 hours ago, Mr Plodd said:

 

A manufacturer can . assign whatever MTPLM they wish PROVIDING it doesn’t exceed the Type Approved MTPLM for that vehicle. Yes it’s seems bizarre but that’s how it is. 

 

Andy

 

If they assign a value that is less than the type approved MTPLM then it can't be an MTPLM. A maximum is a maximum and therefore something absolute. There can't be such a thing as lesser maximum and a larger maximum (unless specifically referred to as such to distinguish the difference) or else it would make a mockery of the definition of the term.

 

Edited by Lutz

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11 hours ago, Paul90125 said:

Whew! Thanks guys!

 

I bet you wish you hadn't bothered asking!

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2 hours ago, Lutz said:

 

If they assign a value that is less than the type approved MTPLM then it can't be an MTPLM. A maximum is a maximum and therefore something absolute. There can't be such a thing as lesser maximum and a larger maximum (unless specifically referred to as such to distinguish the difference) or else it would make a mockery of the definition of the term.

 

That's why it's a "technical" maximum ;)  M.aximum T.echnically P.ermissible L.aden M.ass 

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1 hour ago, Flat_at said:

That's why it's a "technical" maximum ;)  M.aximum T.echnically P.ermissible L.aden M.ass 

 

But you can't have two 'technical maximums', unless the maximum is qualified somehow. So a 'maximum technical maximum' and an 'allocated technical maximum'. Then you have the issue of defining which of those two maximums are used with licencing restrictions and which to vehicle weight limits and explaining the difference to those with a licence weight restriction.

 

That raises an issue that I've not seen aired before. Say you have a licence weight restriction, which as we know is based on MTPLM plus GVW of the car and caravan and your van complies. Supposing you load it to the van's chassis limit (maximum technical maximum) and you are weighed by enforcement. Will you have broken the law? Your van has a manufacturer's plate advising of the lower limit, so you've not broken the MTPLM/GVW plated limits, which is what licencing law requires, but you've loaded up to the chassis limit which is covered by the VIN plate required by Type Approval, so you've not exceeded the plated MTPLM and so you've not broken the weight limit law either.  If that's the case then the licence restriction law is a waste of space.       

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2 hours ago, Flat_at said:

That's why it's a "technical" maximum ;)  M.aximum T.echnically P.ermissible L.aden M.ass 

 

I think you need to go back to the beginning of the topic to fully understand the dilemma, as Andy has said there is a statutory and enforceable MTPLM, but the manufacturer has also added a lower limit and called it the same.

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A manufacturer has to have any vehicle “Type Approved” to a specific MTPLM. 

 

HOWEVER they can, if they so wish, designate a lower Maximum Gross Weight (but there is no separate way of designating it so it HAS to be called MTPLM and THAT figure is what will be used to determine if any offences (driving licence/weight) have been committed 

 

Years ago there was Maximum Gross Weight, but that was changed by the EU to MTPLM and nothing else can now be used to define max weight.

 

Yes it seems perverse, yes it’s illogical and yes I think it’s plain daft, but, having done all the work detailed in my previous lengthy post I accept that the system IS perverse but that’s how it is. 

 

Andy

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22 minutes ago, Mr Plodd said:

A manufacturer has to have any vehicle “Type Approved” to a specific MTPLM. 

 

HOWEVER they can, if they so wish, designate a lower Maximum Gross Weight (but there is no separate way of designating it so it HAS to be called MTPLM and THAT figure is what will be used to determine if any offences (driving licence/weight) have been committed 

 

Years ago there was Maximum Gross Weight, but that was changed by the EU to MTPLM and nothing else can now be used to define max weight.

 

Yes it seems perverse, yes it’s illogical and yes I think it’s plain daft, but, having done all the work detailed in my previous lengthy post I accept that the system IS perverse but that’s how it is. 

 

Andy

 

So we can now pose the question - When is a MTPLM not an MTPLM

The answer being - When it's a manufacturers MTPLM 

 

You couldn't make it up if you tried :blink::blink::blink:

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7 minutes ago, Mr Plodd said:

A manufacturer has to have any vehicle “Type Approved” to a specific MTPLM. 

 

HOWEVER they can, if they so wish, designate a lower Maximum Gross Weight (but there is no separate way of designating it so it HAS to be called MTPLM and THAT figure is what will be used to determine if any offences (driving licence/weight) have been committed 

 

Years ago there was Maximum Gross Weight, but that was changed by the EU to MTPLM and nothing else can now be used to define max weight.

 

Yes it seems perverse, yes it’s illogical and yes I think it’s plain daft, but, having done all the work detailed in my previous lengthy post I accept that the system IS perverse but that’s how it is. 

 

Andy

 

One cannot have two different definitions for the same term or else the result is always ambiguous. MTPLM is defined quite clearly in the respective legislation. Any figure lower than that cannot be a maximum. The figure that the NCC has defined (in accordance with BS EN 1645-2) and which the manufacturer displays on a label next to the door is neither a maximum nor technical (because it is based purely on a calculated value, not on any technical constraints), so both the 'M' and the 'T' are out of place if called an MTPLM. Therefore, another term must be used to describe it.

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9 minutes ago, Lutz said:

 

One cannot have two different definitions for the same term or else the result is always ambiguous. MTPLM is defined quite clearly in the respective legislation. Any figure lower than that cannot be a maximum. The figure that the NCC has defined (in accordance with BS EN 1645-2) and which the manufacturer displays on a label next to the door is neither a maximum nor technical (because it is based purely on a calculated value, not on any technical constraints), so both the 'M' and the 'T' are out of place if called an MTPLM. Therefore, another term must be used to describe it.

 

OK, why don’t YOU try and get a wholly definitive answer as I did? Rather than just posting the arguments I already have put to both the DFT and DVSA. 

 

I dont disagree with the the fact that it’s bizarre and totally illogical, but I have tried my hardest on behalf of everyone, rather than just post disagreements as you are doing. 

 

Andy

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Mr Plodd has described things correctly. A newly purchased van would come with its standard MTPLM, or it may be upgraded at customer request. Either way you submit your proposal to the insurer who never asks the MTPLM and must therefore be unconcerned that it is a modification carrying an increased risk. Therefore a later plate upgrade is no different from having it done at new.

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On 21/03/2019 at 13:17, Mr Plodd said:

Well I suggest YOU take up the matter with the DFT DVSA or whoever else you wish to.   I got an answer from a senior man at the DVSA that I,  as someone who was closely involved in road traffic law for thirty years, I was happy with.

Clearly thats not good enough for you, that’s your choice but, to quote Dragons Den, I’m out!

I am more than happy to be proven wrong, so I challenge you to do eaxactly that.  But that will need proof not opinion.

Andy

TBH sometimes I think that the DVSA or VOSA as they were previously known make it up as they go along.  I do recall a copy of a letter being posted on a caravan forum where the VOSA person definitely stated that the sticker on the body work of the trailer could not be used to prosecute as it was not a mandatory plate. 

 

However perhaps things have changed however Lutz is correct in stating that MTPLM is not used in any legislation so how can any DVSA agent prosecute if the legislation does not exist even on post 2012 trailers?  Best is to stay within the guidelines offered by the caravan manufacturer and avoid any hassles!  :D

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So in simple terms, use the figures on the sticker on the outside of the van unless you would prefer to argue the figure inside is appropriate if it came to it.

 

We upgraded ours to 1300kg, new sticker and manufacturers certificate but no physical changes (even the tyre pressures) - was it a waste of money? Probably, but it covers me off in all eventualities.

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